Short answer
A cylinder that turns up dented, rusted, with a bent valve, without its cap, with a torn label or with markings that do not agree with each other raises two separate problems. Do not mix them.
- Physical safety is settled by the product safety data sheet, sections 2, 4, 6 and 7. The F-gas Regulation does not tell you what to do with a damaged pressure receptacle.
- Compliance is settled by Regulation (EU) 2024/573: the label (Article 12), the ban on non-refillable containers (Article 11(3)), the declaration of conformity for refillable containers (Article 11(4)) and the precautions you owe while the cylinder is in your possession (Article 4(3)).
The practical order never changes: get people safe, freeze the situation, document it, then write to the supplier. A cylinder that has been set aside and photographed properly can still be sorted out. One that has been opened, wheeled around the warehouse and signed for cannot.
No dangerous-goods thresholds, substance identification numbers for transport, packaging limits or vehicle marking rules. No national complaint procedures, forms or deadlines for notifying authorities either, because the Regulation does not set those. This page states what the Regulation requires and points at where the rest comes from.
Safety first: the first few minutes
Refrigerants are delivered as liquefied gases under pressure. A real product sheet classifies them under Regulation (EC) No 1272/2008 with hazard statement H280, warning that the container holds gas under pressure and may explode if heated, and section 2.3 adds asphyxiation at high concentrations and cold burns on contact with the liquid.
Section 7.1 of the same sheet carries the instructions that matter at goods-in: only experienced and properly instructed persons should handle gases under pressure; containers must be protected from physical damage and must not be dragged, rolled, slid or dropped; valve protection caps stay in place until the container is secured; and cylinders are moved on a trolley designed for the job, even over short distances.
If you hear a leak, smell something unusual or see frost on the shell, section 6.1 gives the response: act in accordance with the local emergency plan, evacuate the area, ensure adequate ventilation, stay upwind, and prevent the gas from entering sewers, basements or workpits. Anyone entering the area does so with self-contained breathing apparatus.
Do not crack the valve to see whether there is still gas in it. Do not try to straighten a bent valve or tighten a leaking gland. Do not vent the cylinder to make it harmless — Article 4(1) prohibits the intentional release of fluorinated greenhouse gases where the release is not technically necessary for the intended use.
First aid, if anyone has been exposed, is in section 4: the casualty is removed from the area by equipped personnel, frostbite or eye contact is flushed with water for at least 15 minutes, and medical help is obtained. Read the sheet for the actual product, not a similar one — see the guide on reading a safety data sheet.
What you see, what it means, what you do
The table below follows the order an experienced receiver works in: the shell and the valve first, then the stamped markings, then the label, then the paperwork.
| What you see | What it can mean | What you do |
|---|---|---|
| Deep dent, bulge, gouge or fire damage on the shell | The integrity of the pressure receptacle can no longer be assumed | Do not use it, move it as little as possible, isolate it and tell the supplier |
| Bent, cracked or leaking valve, protection cap missing | Direct risk of uncontrolled release | Do not touch the valve, ventilate, keep people away |
| Heavy rust, corrosion, unreadable stamped markings | The identity of the cylinder and its inspection history cannot be established | Quarantine; see the periodic inspection date |
| Label missing, torn, illegible or in the wrong language | The requirements of Article 12(3) and (4) are not met | Do not supply it on; ask the supplier for a compliant label |
| The designation on the label does not match the delivery note or the sheet | Wrong product, or a product described wrongly | Quarantine; see label does not match the SDS |
| A cylinder built to be thrown away, with no return arrangement | A non-refillable container, prohibited by Article 11(3) | Do not take it into stock; see non-refillable cylinders |
| Seals, colours or markings that look copied, a batch that cannot be verified | Possible counterfeit or illegally traded product | Quarantine and follow the counterfeit refrigerant procedure |
One row from this table is enough to stop the receipt of that cylinder. You do not need a full set.
The legal checks, article by article
Once the situation is safe, move to compliance. There are four checks, all of them in Regulation (EU) 2024/573.
1. The label. Article 12(1), point (g) puts all fluorinated greenhouse gas containers under the labelling obligation. Article 12(3) says what the label must carry: an indication that the product contains fluorinated greenhouse gases, the accepted industry designation (or the chemical name where none exists), the quantity expressed in weight and in CO2 equivalent, and the global warming potential of those gases. Article 12(4) requires the label to be clearly legible and indelible, placed adjacent to the service ports or on the part containing the gas, and written in the official languages of the Member State in which the good is to be placed on the market, made available or supplied.
Implementing Regulation (EU) 2024/2174 adds the format: Article 1(1) requires the information to stand out clearly from the background and be readable, Article 1(2) requires the label to stay securely in place and legible under normal operating conditions for the whole time the product contains the gases, and Article 1(3) prescribes an explicit statement that the product contains fluorinated greenhouse gases. Article 1(7) lists the extra wording for recycled or reclaimed gas and for gas destined for specific uses.
2. Refillable containers only. Article 11(3) prohibits the import, any subsequent supply, making available, use or export of non-refillable containers for the gases listed in Annex I and in Section 1 of Annex II, whether empty or fully or partially filled. The second subparagraph defines two cases: containers that cannot be refilled without being adapted for that purpose, and containers that could be refilled but are imported or placed on the market without provision having been made for their return for refilling.
3. The declaration of conformity. Article 11(4) requires undertakings that place refillable containers on the market to produce a declaration of conformity including evidence that binding arrangements are in place for the return of those containers for refilling, identifying the relevant actors, their obligatory commitments and the logistical arrangements. The declaration is kept for at least 5 years from the placing on the market. Suppliers to end users keep evidence of compliance with those arrangements, also for at least 5 years.
4. The gas inside. If the label says the gas is reclaimed or recycled, Article 12(7) requires that indication, and in the case of reclamation also the batch number and the name and address of the reclamation facility in the Union. Those details missing from a product sold as reclaimed is a non-conformity you can see with the naked eye.
The receiving procedure, step by step
Stop the receipt before you sign
Do not sign for a cylinder you have doubts about. A signature given and then disputed is a far harder conversation than a receipt stopped in time.
Look and listen before you touch
Hissing, frost on the shell, an unusual smell, an oil stain under the valve. Section 6.1 of the safety data sheet calls for evacuation and ventilation where gas is being released.
If gas is escaping, people go first
Evacuate, ventilate, stay upwind, keep the gas out of basements and workpits. Do not open or close the valve at random.
Photograph before anything moves
The shell from four angles, the valve, the cap, the stamped markings, the whole label, the delivery note and the state of the pallet. Photographs are the one piece of evidence that cannot be reconstructed later.
Compare the label with the paperwork
Designation, quantity in weight and in CO2 equivalent, GWP and the language of the label, under Article 12(3) and (4). Then compare with the delivery note and the safety data sheet.
Record the identity of the cylinder
Cylinder number, stamped markings, batch or serial number on the label, quantity and delivery date. Without them the complaint turns into an argument about some cylinder or other.
Put the cylinder in quarantine
A separate marked area, valve closed, cap fitted, cylinder secured against falling, away from heat sources and traffic routes. Article 4(3) and (4) require precautions for as long as you hold it.
Write to the supplier the same day
The facts, the photographs, the identity of the cylinder and what you are asking for: return instructions, replacement or a credit note. In writing, not by phone.
Decide the route back last
The return journey of a full or partly full cylinder is governed by dangerous goods law, not by the F-gas Regulation. See the section below.
Quarantine and the evidence file
For as long as the cylinder is with you, you are the undertaking in possession of the equipment. Article 4(3) requires operators, manufacturers and undertakings in possession of such equipment during its transport or storage to take all necessary precautions to prevent unintentional release and all technically and economically feasible measures to minimise leakage.
Article 4(4) goes further: during storage, transport and transfer from one container to another, the undertaking concerned takes all necessary precautions to limit release to the greatest extent possible. Article 4(5) then requires repair without undue delay where a leak is detected, and it places that duty on the undertaking in possession of the equipment during transport or storage as well.
In practice, quarantine means a defined, marked place where the cylinder stands upright and secured; a closed valve with the cap fitted; a written ban on use; and a tag physically attached to the cylinder showing the date, the reason and the person who stopped it.
Dated photographs; the cylinder number and stamped markings; the batch shown on the label; the delivery note and the invoice; the safety data sheet you received; the correspondence with the supplier; and the internal note recording the quarantine decision. That is the file you can put on the table during a check without reconstructing anything from memory.
If the cylinder eventually goes for disposal, Article 8(7) requires an undertaking that uses a container holding gases listed in Annex I or in Section 1 of Annex II to arrange, immediately prior to disposal, for the recovery of any residual gases so that they are recycled, reclaimed or destroyed. Recovery is carried out by persons certified under Article 10, and recovered gas may not be used for refilling unless it has been recycled or reclaimed (Article 8(6)). More in the recovery guide.
Telling the supplier, the authority, and the journey back
Tell the supplier in writing. The Regulation prescribes no form, but it prescribes consequences: if the cylinder is not compliant you cannot supply it on. Article 11(1), third subparagraph says expressly, for products and equipment unlawfully placed on the market, that they shall not subsequently be used, supplied or made available to other persons within the Union for payment or free of charge, nor exported.
The competent authority. The Regulation creates no general duty to report every dented cylinder. What Article 29 says is that the competent authorities of Member States carry out checks following a risk-based approach, and that they also carry out checks when they are in possession of evidence or other relevant information, including based on substantiated concerns provided by third parties, concerning potential non-compliance. In other words, a substantiated report from you is a trigger the text itself provides for. Checks include on-site visits and verification of documentation and equipment, and are carried out without prior warning unless prior notification is necessary to make them effective.
Where the product looks counterfeit or illegally traded, do not improvise: follow the steps in the guide on counterfeit and illegal refrigerant, which handles that case separately.
A full or partly full cylinder with a damaged valve or a damaged shell does not simply go into a van. The applicable regime is dangerous goods law — inside the Union, Directive 2008/68/EC on the inland transport of dangerous goods. Classification, the proper shipping name, packing conditions and documents come from that regime and from section 14 of the safety data sheet for the product, in the format required by Regulation (EU) 2020/878. Ask the supplier for written return instructions and, where needed, a carrier able to take a damaged package.
For responsibility while the cylinder is moving, see transporting cylinders. For the normal return loop, cylinder return and refilling. For the paperwork that should have arrived with the delivery, documents with a cylinder.
Goods-in checklist
- The area is safe and ventilated before anything is touchedSections 6 and 7 of the product safety data sheet.
- The valve has its cap and has not been operatedHandling gases under pressure is reserved to instructed persons, per section 7.1 of the sheet.
- The shell shows no deep dents, bulges or fire damageThe integrity of a pressure receptacle is assessed under legislation other than the F-gas Regulation; in case of doubt the cylinder is not used.
- The stamped markings are legibleWithout them you cannot establish the identity of the cylinder or its periodic inspection history.
- The label carries everything Article 12(3) requiresThe fluorinated greenhouse gas statement, the designation, the quantity in weight and in CO2 equivalent, and the GWP.
- The label is legible, indelible and in the language of the destinationArticle 12(4), including the second subparagraph on official languages.
- The cylinder is refillable and a return arrangement existsArticle 11(3) and the declaration of conformity under Article 11(4).
- Photographs and the cylinder identity are savedCylinder number, batch, quantity, date, delivery note. Before anything is moved.
- The cylinder is in marked quarantine, secured, valve closedThe precautions in Article 4(3) and (4) apply for as long as you hold it.
- The written notification to the supplier went out the same dayWith facts, photographs and a clear request. A phone call leaves no trace.
Frequently asked questions
Can I simply refuse the delivery?
Refusal is a contractual matter between you and the supplier, not something Regulation (EU) 2024/573 governs. What the Regulation says is that if you accept the cylinder you fall under Article 4(3) as the undertaking in possession of the equipment, and that if the cylinder is not compliant you cannot supply it on. In practice a damaged cylinder is more often accepted into quarantine than physically refused, because refusing it sends it back onto the road in exactly the state it is in.
The label is in the supplier's language, not mine. Is that a problem?
Yes. Article 12(4), second subparagraph requires the label to be written in the official languages of the Member State in which the good is to be placed on the market, made available or supplied. What counts is the commercial destination, not the origin. Ask the supplier for a compliant label before you make the cylinder available any further.
The cylinder is declared empty. Does anything still apply?
Yes. A cylinder declared empty almost always holds residual gas, and Article 8(7) requires the undertaking using the container to arrange for the recovery of residual gases immediately prior to its disposal. Until then the precautions in Article 4(3) still apply, and the Article 11(3) prohibition on non-refillable containers applies to empty containers too.
Who pays for recovering the gas from a damaged cylinder?
The Regulation allocates duties, not costs. Article 8(1) requires recovery by certified persons and Article 8(7) requires it immediately prior to disposal of the container. Who bears the cost is settled in the contract and in the correspondence with the supplier — one more reason to have a written notification from day one.
Do I have to inform the competent authority?
The Regulation imposes no general notification for a damaged cylinder. Article 29(2) does provide that authorities carry out checks when they hold evidence or other relevant information, including substantiated concerns provided by third parties, concerning potential non-compliance. If you have indications of a counterfeit product or of illegal trade, your report feeds exactly that mechanism. How a report is filed is set nationally, not in the Regulation.
Can I transfer the gas into another cylinder to save the goods?
Transfer from one container to another is covered by Article 4(4), which requires all necessary precautions to limit release to the greatest extent possible, and it is carried out by personnel certified under Article 10. The receiving container must also be suitable for the product and correctly relabelled under Article 12(6) after refilling. It is not an operation to improvise at the loading bay.
How is this different from a label that simply disagrees with the SDS?
Here the problem is the physical state of the receptacle or a sign of legal non-compliance visible at goods-in. A mismatch between the designation on the label and the one in the safety data sheet has its own decision path, covered in the dedicated guide.
Official sources
Articles 4, 8, 11, 12 and 29 were read directly in the Official Journal text. The safety part comes from the mandatory safety data sheet format and from a real product sheet. The dangerous goods regime is named through the applicable act, without reproducing its numerical thresholds.
How current this page is, and the limits of our liability
This page sets out the duties in the F-gas Regulation and points at the safety data sheet for the safety part. It does not replace the judgement of a competent person on site and it does not contain the numerical thresholds of dangerous goods law. A damaged cylinder under pressure is handled only by trained personnel with the right equipment.
General information prepared by EgoLog on the basis of the Regulation, the implementing regulations and official Commission material. It is not legal advice.
Pressure receptacle inspection and the periodic testing of cylinders fall under acts other than the F-gas Regulation. Confirm those requirements with your supplier and your national competent authority before taking a commercial decision.